Transfer Pricing and Financing
Raffaele Petruzzi
Sold by AHA-BUCH GmbH, Einbeck, Germany
AbeBooks Seller since 14 August 2006
New - Hardcover
Condition: New
Ships from Germany to U.S.A.
Quantity: 2 available
Add to basketSold by AHA-BUCH GmbH, Einbeck, Germany
AbeBooks Seller since 14 August 2006
Condition: New
Quantity: 2 available
Add to basketIn recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties.
Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions:
loans;
financial guarantees;
cash pooling;
hybrid financing;
factoring;
captive insurance; and
asset management.
Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law.
Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
"About this title" may belong to another edition of this title.
General Terms and Conditions and Customer Information / Privacy Policy
I. General Terms and Conditions
§ 1 Basic provisions
(1) The following terms and conditions apply to all contracts that you conclude with us as a provider (AHA-BUCH GmbH) via the Internet platforms AbeBooks and/or ZVAB. Unless otherwise agreed, the inclusion of any of your own terms and conditions used by you will be objected to
(2) A consumer within the meaning of the following regulations is any natural person who concludes...
**Right of withdrawal for consumers **
(A consumer is any natural person who concludes a legal transaction for purposes that can predominantly be attributed neither to their commercial nor their independent professional activity.)
Cancellation
Withdrawal
You have the right to revoke this contract within fourteen days without giving reasons.
The revocation period is fourteen days from the day,
on which you or a third party named by you, who is not the carrier, has taken possession of the goods, provided that you have ordered one or more goods within the framework of a uniform order and these are or will be delivered uniformly;
on which you or a third party named by you, who is not the carrier, has taken possession of the last goods, provided that you have ordered several goods within the framework of a single order and these are delivered separately;
on which you or a third party named by you, who is not the carrier, has taken possession of the last partial shipment or the last piece, provided that you have ordered goods that are delivered in several partial shipments or pieces;
In order to exercise your right of withdrawal, you must inform us (AHA-BUCH GmbH, Garlebsen 48, 37574 Einbeck, telephone number: 05563 9996039, fax number: 05563 9995974, e-mail address: service@aha-buch.de) of your decision to revoke this contract by means of a clear declaration (e.B. a letter sent by post, fax or e-mail). You can use the attached model withdrawal form, but this is not mandatory.
To comply with the revocation period, it is sufficient that you send the notification of the exercise of the right of revocation before the expiry of the revocation period.
Consequences of revocation
If you withdraw from this contract, we shall reimburse you all payments that we have received from you, including delivery costs (with the exception of the additional costs resulting from the fact that you have chosen a different type of delivery than the cheapest standard delivery offered by us), immediately and at the latest within fourteen days from the day on which we received the notification of your revocation of this contract.
For this repayment, we will use the same means of payment that you used for the original transaction, unless expressly agreed otherwise with you; in no case will you be charged any fees for this repayment.
We may withhold reimbursement until we have received the goods back or until you have provided proof that you have returned the goods, whichever is the earlier.
You must return or hand over the goods to us immediately and in any case at the latest within fourteen days from the day on which you inform us of the revocation of this contract. The deadline is met if you send the goods before the expiry of the period of fourteen days.
You bear the direct costs of returning the goods.
You only have to pay for any loss of value of the goods if this loss of value is due to handling of the goods that is not necessary to check the nature, characteristics and functioning of the goods.
Reasons for exclusion or extinction
The right of revocation does not apply to contracts
The right of revocation expires prematurely in the case of contracts
Sample withdrawal form
(If you want to cancel the contract, please fill out this form and send it back.)
To AHA-BUCH GmbH, Garlebsen 48, 37574 Einbeck, fax number: 05563 9995974, e-mail address: service@aha-buch.de :
I/we () hereby revoke the contract concluded by me/us () for the purchase of the following goods ()/
the provision of the following service ()
Ordered on ()/ received on ()
Name of the consumer(s)
Address of the consumer(s)
Signature of the consumer(s) (only in case of notification on paper)
Date
(*) Delete as appropriate.
We ship your order after we received them
for articles on hand latest 24 hours,
for articles with overnight supply latest 48 hours.
In case we need to order an article from our supplier our dispatch time depends on the reception date of the articles, but the articles will be shipped on the same day.
Our goal is to send the ordered articles in the fastest, but also most efficient and secure way to our customers.
| Order quantity | 30 to 40 business days | 7 to 14 business days |
|---|---|---|
| First item | £ 54.26 | £ 62.90 |
Delivery times are set by sellers and vary by carrier and location. Orders passing through Customs may face delays and buyers are responsible for any associated duties or fees. Sellers may contact you regarding additional charges to cover any increased costs to ship your items.